Way past 5 o'clock and I can't think straight! Can we consider a Phase II CTR exemption for a DBA account?

Customer is a sole proprietor who owns a small grocery. Account is a business checking product type. Account is set up under owner's SSN. Does not have a separate EIN.

Long time customer whose activity meets all the other exemption criteria. I'm just hung up on the ownership aspect.

Exempting a sole proprietor's transaction accounts (checking and money market) is permissible. The challenge is demonstrating that the business is organized within a state since a sole proprietorship does not have to register with the Secretary of State.

Related Thread

Question 15

To document the sole proprietor's business is a "bona fide business", could we use a business license (if they have one), documentation where they are licensed to sell lottery tickets with the state, or state sales tax payment records?

If you think that is: " Is incorporated or organized under the laws of the United States or a State, or is registered as and eligible to do business within the United States or a State", then go for it.

But the question remains, since there is no separation between the individual and their "dba" - how do you make sure that any cash deposits or withdrawals are related to the business??